IA-86-396, Concurs W/Comments Transmitted to J Starmer on 851230 Re Draft Environ Assessment for Disposal of Project Low Level Waste at West Valley,Ny.Doe Should Be Urged to Address long- Term Performance Objectives Per Site Suitability Criteria
| ML20202G153 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/1986 |
| From: | Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20198M712 | List:
|
| References | |
| FOIA-86-396, REF-PROJ-M-32 NUDOCS 8607150312 | |
| Download: ML20202G153 (2) | |
Text
_ _ - - _ _ _ _ - _ _ _ _ _ _
h UNITED STATES f <> NUCLEAR HEGULATORY COMMISSION )
U $ WASHINGTON, D. C. 20555 i.
% .*** ^' br t. h 7 ,( D g ,
MEMORANDUM FOR: Leo Higginbotham, Chief WMLU FROM: Malcolm Knapp, Chief WMGT StlRJECT: WMGT REVIEW 0F DOE ENVIRONMENTAL ASSESSMENT (EA) FOR DISPOSAL OF PROJECT LLW AT WEST VALLEY, NEW YORK WMGT staff has completed its review of the subject document and finds no reason to alter the comments made on the Draft Environmental Assessment (DEA) and transmitted by memorandum to John Starmer en December 30, 1985. We note the attempt to address those comments in Section 3.1.3, Regulations and Criteria.
That section indicates that the intent of the EA is to conform to the Performance Obiectives of 10 CFR Part 61. However, the EA does not consider i the Site Suitability Requirements of 10 CFR Part 61.50 to be applicable because j the proposed site t considered to be part of an existing disposal facility. 4 i
WMGT considers the intent of the Site Suitability Requirements is to ensure ;
that the long-term Performance Objectives are met. Failure to consider the i Site Suitability Requirements raises the possibility that the Performance !
Objectives may be difficult to achieve. We therefore recommend that the DOE be urged to address the Performance Objectives in sufficient detail to resolve this concern. If dcne at an early stage, DOE may reconsider our earlier recommendation to consider alternatives to continued disposal of LLW at West Valley.
Additional detailed concerns regarding the site groundwater system are enclosed. Should you require further assistance, please contact Richard Lee or !'
Lynn Deerina of my staff directly. '
YY Malcolm Knapp, Chief WMGT
Enclosures:
As stated l
l h$ 71 g 2 86070s RESNIKOB6-396 PDR O
f.
i
... .- )
3 x .
I 1.) Item no. 7 in the December 30th memo indicates that the history of water accumulation in the trenches at West Valley will likely continue in the proposed trenches as the unstable class A wastes collapse, resulting in trench cap failure. This "bathtubbing" may result in leachate seepage into the weathered Lavery Till zone. There is sufficient evidence based on the discovery of kerosene TBD migration that solvent, or perhaps any liquid, can be rapidly transported either through the weathered till or along the unweathered/ weathered till interface. The GT staff therefore suggests that measures be implemented to solidify / stabilize these class A wastes as a precautionary measure in the event that infiltration occurs due to trench cap failure. Because there may be additional factors besides infiltration through the trench caps, the staff suagests that the assumption stated in the Draft EA that no migration will occur during the period of institutional control (P.
G-52), should be reevaluated and incorporate additional factors.
2.) Item no. 2 of the December 30th memo indicates that the Draft EA lacks sufficient documentation of the site hydrogeology for the staff to assess the suitability of the site with respect to its capability of being modeled, l characterized and analyzed (10 CFR Part 61.50 a). The staff recommends that a more thorough presentation of the hydrogeologic characterisitics of the site be included in the Draft EA. Characterization of the shallow ground water system and pathways (weathered till zone) is of particular importance in understanding the " driving mechanism" of this shallow flow system and it's relationship to the deeper flow system (NUREG-1164). Hydrogeologic information presented should include the rate of water infiltration into the disposal trenches, the extent and nature of recharge into the shallow ground water flow system, possible lateral flow and transport pathways, hydralic gradients, and perhaps reevaluated hydraulic conductivity values (present values may be too low). This information should be clearly defined in the ground water modeling section of the Draft EA in terms of input values, boundary conditions and current hydrologic conditwns.
3.) The ground weter quality and related geochevical characteristics of the site should t,e included in the Draft EA.
4.) Until a detailed design of the above ground tumulus is presented in the Draft EA, the staff connot make comments concerning the possible impacts that the tumulus may have on the site with respect to local ground water and surface water flow, drainage, flooding, and erosion. i l
l l^ l l
1 l
~ _ . . . _ _
j